The proposals are in an extremely long and almost impenetrable submission by the EASA. It is not easy to give a concise reply to how they differ from a report as there is so much in them, most of which does not involve fatigue and its management.
But in essence, on the subject of fatigue, the proposals do not acknowledge the indepndent scientific evidence that was used to create the Moebus report, or even CAP371. For example, time on standby can no longer be included in duty time calculations. Theoretically you can be on standby all day and then, 10 minutes before the standby ends, be called out on a maximum duty day, as if you had just been woken after a full nights sleep. The restrictions on the maximum numbers of night duties and duty hours in a set period of time have been revised upwards, redefined or just ignored altogether. The list goes on and on.
CAP371 has the credibility of independent scientific scrutiny. It didn't 'just happen' but was created in 1970 by a committee chaired by Douglas Bader in response to concerns in the airline industry that crew fatigue lacked a formalised framework over what was and what was not reasonable and safe. Since then it has been revised, reviewed and updated in the light of new technology, new research and airline pressure.
None of these claims could be made by the EASA about their proposals. CAP371 is not a cosy little protectionist pocket to protect spanish practices in the airline industry. It affords those who do the job, day in and day out, with a measure of protection against the undeniably fatiguing nature of our job. The limitations within it have often been bought, quite literally, with blood.
The UK airline industry is at the forefront, globally, of commercial innovation and competitiveness. We achieve this with one of the highest levels of safety in the world, and within the limtations of CAP371. I, for one, would need to see utterly convincing evidence of necessity, before condoning any reduction in the safety regime we currently enjoy.